Global Tax Policy and Controversy BriefingIssue 18 | October 2016

This is an excerpt from the Global Tax Policy and Controversy Briefing. For the complete edition, go to www.ey.com/tpc.

“ It’s quite an exciting time, as we now move to rebalance the global approach to tax policy. We had BEPS to fight tax avoidance, and we have transparency to tackle tax evasion — we now need to have tax certainty to rebalance all of that.”

— Insights from Pascal Saint-Amans,

Director of the Centre for Tax Policy and Administration

of the Organisation for Economic Co-operation and

Development

12insights

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inside issue 187 Brexit and UK taxation

12 Insights from Pascal Saint-Amans, Director of the Centre for Tax Policy and Administration of the Organisation for Economic Co-operation and Development

14 G20 leaders focus on promoting growth through tax policy

19 The EU’s tax agenda for 2016/2017

29 An EY study on tax competition and the proposed common tax base for corporate income tax in Europe

33 GST: A new era of cooperative federalism in India

37 Running the numbers: how data analytics is transforming tax administration

43 country updates

44 Japan Japan postpones consumption tax increase

46 Mexico Mexican Supreme Court of Justice declares certain electronic accounting requirements unconstitutional, validates others

48 UK UK amends mandatory requirement for businesses to publish tax strategy

52 US Trump vs. Clinton: their tax proposals

65 EY contacts

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Global Tax Policy and Controversy BriefingIssue 18 | September 2016

We are delighted to welcome Marlies de Ruiter, former Head of the Tax Treaty, Transfer Pricing and Financial Transactions Division (TTP Division) at the Centre for Tax Policy and Administration of the OECD, to EY. Under her leadership at the OECD, the TTP Division developed seven of the 15 actions of the BEPS Action Plan. Before joining the OECD, Marlies gained more than 20 years of experience in the fields of direct taxation and international tax issues within the Dutch Ministry of Finance. Her vast experience with international tax policy, and specifically with BEPS, will demonstrate our leading position in the market on BEPS-related matters.

Marlies is joining us to work on Tax Policy and International Tax Services.

Welcome to EYMarlies de Ruiter

4 Global Tax Policy and Controversy Briefing

As we head into the last quarter of the year, the themes that will dominate

the next year are becoming clearer. Given diminishing forecasts for growth, it should come as no surprise that fostering growth and the role that tax policy can play to grow economies and address budget deficits is under active discussion. In fact, at the recent G20 summit in Hangzhou, China, the role of taxation in promoting innovation-driven, inclusive growth was a key agenda item.

As Jeffrey Owens explains on page 15, and Pascal Saint-Amans of the Organisation for Economic Co-operation and Development previewed at the EY aHead of Tax client event in June, the G20’s focus on boosting growth through tax could usher in another era of significant tax reform — one that will extend beyond the Base Erosion and Profit Shifting agenda and could encompass all components of countries’ tax systems. See the article on page 52 outlining what the US presidential candidates are thinking about US tax reform.

Another trend we’re seeing relates to the developments in digital tax administration. To cope with the growing pace and volume of taxpayer information flowing between governments and businesses, many tax authorities are increasingly relying on digital methods to collect and analyze this data. As the article on page 37 explains, it is critical that companies respond to the new era of digital tax compliance by reviewing their data management and analytics capabilities to check that they can meet the requirements and rapid turnaround times being demanded by tax authorities.

Meanwhile, in the European Union (EU), the intense focus on multinational companies’ tax affairs continues. To date, most of the attention has been on the alleged State Aid violations involving tax rulings granted by EU Member States to multinational companies. But, as Klaus von Brocke and Steve Bill explain on page 19, the EU’s tax agenda covers much more than the State Aid investigations. For example, the European Parliament has set up an inquiry committee into the so-called Panama Papers’ revelations. In addition, the European Commission has adopted a wide-ranging action plan intended to modernize the current EU value-added tax rules, is gearing up for a November relaunch of the common

consolidated corporate tax base proposal and has proposed a directive that would require large multinationals to publicly report tax information on a country-by-country basis.

Continuing the interest in public reporting of tax, the UK has recently enacted new rules requiring certain businesses to publish their tax strategy as it relates to affects UK taxation (Paul Dennis and Geoff Lloyd provide more details on page 48). With the recent introduction in Australia of a voluntary tax transparency code, which encourages medium and large businesses to publicly disclose how much tax they pay and explain their tax strategies, such transparency initiatives could herald many more. Companies should expect to see governments begin to require greater public transparency as to how their profits are taxed, where their intangible assets are located and the underlying rationale for their business decisions.

Once again, we are in a busy period of tax policy changes and proposals, leading to and driven by tax controversy. For businesses seeking to put this all in perspective and gain insight into what may come next, this edition of the Global Tax Policy and Controversy Briefing provides food for thought.

WelcomeGlobal Tax Policy and Controversy Briefing 5

Rob HansonEY Global Director, Tax Controversy Services, Ernst & Young LLP +1 202 327 5696 rob.hanson@ey.com

Chris SangerEY Global Director, Tax Policy Services, Ernst & Young LLP +44 20 7951 0150 csanger@uk.ey.com

6 Global Tax Policy and Controversy Briefing

More than three months after the initial shock of the Brexit vote, the financial markets

and the political environment seem to have stabilized. Although it is still early days, the vote’s initial impact on the UK economy seems to have been limited. However, as the challenges ahead of us start to become clearer, it is worth remembering this is only the beginning of a very long journey.

While taxation is a relatively undeveloped aspect of the acquis communautaire, given Member States’ reluctance to cede fiscal sovereignty to the EU, the tax implications of Brexit will be substantial, with the consequences being felt beyond the UK and the EU. Businesses will need to understand and be able to respond to changes in the tax landscape that are likely to be unprecedented in terms of both volume and speed of implementation. To do so, it will be crucial for companies to closely monitor and assess the Brexit process as it unfolds. This will enable companies to plan effectively for both the short and long term.

Where are we now?The referendum result had an immediate impact on both the economy and the political landscape in the UK.

EconomyAlthough the consensus is that the UK economy will slow down as a result of the Brexit vote in the short- to medium-term, it has so far proved more resilient in the immediate aftermath than many economists had anticipated. The Organisation for Economic Co-operation and Development (OECD) recently revised upward its forecast for growth this year as a result of a stronger-than-expected performance in the first half of 2016 and action taken in August by the Bank of England to spur activity.

The OECD said it expects the UK economy to grow by 1.8% this year, a 0.1 point increase on its pre-referendum estimate, but then fall by more than it had previously envisaged, and grow by 1% in 2017. The output of the services sector — the steam engine of the UK economy — as well as retail sales seem to be holding strong.

While we still have no hard post-vote data on business investment, the area most vulnerable to Brexit-related uncertainty, official numbers so far offer cause to think that a negative reading for gross domestic product (GDP) growth in Q3 is a remote prospect. The EY ITEM Club now expects that GDP will expand by around 0.2% in Q3.

Overall, while the gloomier predictions around the Brexit vote are unlikely to be realized, the economy is not out of the woods yet, and the long term impact of the Brexit vote on both the UK and global economies remains uncertain.

As for the short-term consequences for the UK economy, the EY ITEM Club Summer Forecast, published in July 2016, suggests that severe confidence effects on spending are very likely, only partially cushioned by a fall in the pound. The UK economy is expected to grow by 1.9% in 2016, followed by only 0.4% in 2017 and 1.4% in 2018, compared to pre-Brexit forecasts of 2.6% and 2.4% respectively. This slowdown in the economy has curtailed the chances of achieving a budget surplus by the end of the decade. We now expect to see borrowing of 1.7% of GDP for 2019–20. A new EY ITEM Club forecast will be published on 17 October.

PoliticsThe immediate political fallout from the vote saw the departure of many of the senior figures of the Remain campaign (the resignation of David Cameron and the sacking of George Osborne and Michael Gove). However, the political landscape removed additional uncertainty when the Conservative party avoided a lengthy leadership battle and a new Government under Theresa May emerged.

Brexit and UK taxation

7Global Tax Policy and Controversy Briefing

Steven EffinghamSenior Manager, Tax,

Ernst & Young LLP +44 20 7951 6342

seffingham@uk.ey.com

Chris SangerGlobal Director,

Tax Policy Services, Ernst & Young LLP

+44 20 7951 0150 csanger@uk.ey.com

Who are the key players? Within the UK, there have been changes of personnel and also changes in the institutional setup. For the tax world, the most significant change is the replacement of George Osborne, long-term Chancellor of the Exchequer under David Cameron, with Philp Hammond. Institutionally, the big innovations are the creation of two new departments of state dedicated to delivering Brexit.

• Philip Hammond, Chancellor of the Exchequer

The new Chancellor has accepted that the Brexit vote means the economy is entering a “new phase” that will require a “different set of parameters” to reduce the deficit. He has ruled out the possibility of an Emergency Budget, preferring to wait for the Autumn Statement on 23 November. As head of Treasury, Hammond will play a crucial role in shaping the tax aspects of the Brexit process.

• David Davis, Secretary of State for Exiting the European Union

He will lead and coordinate the cross-government policy work to support the UK’s negotiations to leave the EU. This will include handling the negotiations with the EU and bilateral discussions with other European countries.

• Liam Fox, Secretary of State for International Trade

He will be responsible for developing, coordinating and delivering a new trade and investment policy for the UK. This includes developing and negotiating free trade agreements and market access deals with non-EU countries, multilateral trade deals and providing operational support for exports, as well as inward and outward investment.

At an official level, we have also seen the setting up, within the key tax departments (HM Treasury and HM Revenue & Customs), of dedicated units responsible for managing the Brexit transition.

Beyond the UK, the key players in the Brexit process will be the leaders of France and Germany and the Presidents of the various EU institutions (the Council, the European Commission and the European Parliament). The relative importance of these players will vary over the life cycle of the Brexit process. Previous experience tells us that when it comes to the big issues, discussions — even if informal — tend to take place between the key players before the European Commission gets involved. Once the exit procedure has been triggered, the EU institutions will come more into play, with a central role being played by the European Commission, which has appointed Michel Barnier as Chief Negotiator in charge of the Preparation and Conduct of the Negotiations with the United Kingdom, and Sabine Weyand, as Deputy Chief Negotiator.

8 Global Tax Policy and Controversy Briefing

So what happens now?The Leave vote will trigger a chain of events against a backdrop of global political change.

Assessing the potential impact on your business Performing alternative scenario analysis

Scenario impact analysis

Customers, markets, geographies

Supply chain, workforce, input costs, distribution

Currency, interest rates, financing, tax

Operations

Scenario models

Revenues Financials

Corporate issuesRegulation, taxation, accounting, legal, etc.

Potential tax and legal implications

Considerations Potential impact

Speed of action

Forex/treasury • What are the tax consequences of managing your treasury position? H M L H M L

Trading model/operating model

• What are the trade, duties and VAT implications for your supply chain?• How will your people functions be affected?• How will you need to adjust your transfer pricing?

H M L H M L

Systems • How will you manage an increased compliance burden, e.g., duties and VAT?• How will it affect entity reporting?

H M L H M L

People • What data do you hold on European nationals working for you in the UK and Britishcitizens working in Europe?

• As the profile of the workforce is set to change, how integrated are your immigration,employment and talent strategies?

H M L H M L

Legal structure • Is your headquarter location fit for purpose?• Could the removal of EU directives impact the tax and legal profile of your existing

group structure?H M L H M L

Regulatory change

• Are you aware to what extent your business relies on EU regulations which might nolonger apply in the future?

H M L H M L

Future of UK Tax • What do you need the UK tax regime to deliver to help you remain competitive? H M L H M L

On 23 June 2016, the people of the United Kingdom voted in a referendum to leave the European Union (EU). Formal withdrawal talks will only be triggered when Britain invokes Article 50 of the Lisbon Treaty, which puts other EU leaders on notice that the UK intends to leave. The UK will have two years from when it invokes Article 50 to negotiate its separation from the EU.

Areas that companies need to consider as they evaluate the impact of the UK EU Referendum on their company, which may vary by industry.

Little may change immediately but now is the time for action.By understanding the possible risks and opportunities, businesses can effectively prepare for the path ahead.

New prime minister Theresa May appointed Prime Minister with responsibility for negotiating the UK’s exit.

13 July 2016

ReferendumJune 2016

UK triggers Article 50?The formal process of negotiating exit begins.

Once notice given, negotiations start and

clock is running — when to give notice?

31 December 2016?

Deal reached?EU Commission negotiates the withdrawal, for approval by the Council of Member States after ratification by the EU Parliament.

2017–18?

UK exits?It’s unclear whether the withdrawal agreement — or a separate one — would cover the UK’s future relationship with the EU.

1 January 2019?

Extension granted?Only possible in the event of a unanimous agreement.

2019?

Treaty provides for two years, could be shorter if agreed or

longer if extended by unanimity

August–October�2017German Federal Election

April-May 2017French Presidential Election

November 2016US Presidential Election

March 2017Dutch general election

Exports to EU, access to markets, imports (supply chain) from EU, impact on customers

Scenario drivers for consideration

Trade People Regulation Government policyImpact on ability to hire skilled and unskilled staff, possible wage pressure, impact on existing staff

Changes to regulation of products and services, impact on business model, standards and future investment

Access to EU research funding, taxation, greater flexibility in design and implementation of investment incentives including the UK competitive tax policy

What happens next?Formal withdrawal talks will only be triggered when Britain invokes Article 50 of the Lisbon Treaty, which puts other EU leaders on notice that the UK intends to leave. The UK will have up to two years from when it invokes Article 50 to negotiate its separation from the EU. Prime Minister May has signaled that this will not happen until early 2017.

What do existing models tell us?During the referendum campaign and after the vote, there has been a good deal of discussion about the different “models” that might be open to the UK in its future relationship with the EU (looking at the existing models operated with Norway, Switzerland and Canada). Faced with the reality of Brexit, it is clear that there is no “off-the-shelf” model that will apply directly to the UK, not least because of the size of the UK’s economy and the extent of its current integration within the EU. Rather, the model for Brexit will emerge from the detailed negotiations between the UK and its EU partners, with the crucial dimension focusing on the balance between access to the Single Market and the maintenance of the free movement of labor.

The greater access to the Single Market that the UK retains, the more it will be bound into the existing legal structures of the Union, including those affecting taxation. However, the more that the UK rejects the free movement of labor, the less likely it is to secure rights to access the Single Market.

Global Tax Policy and Controversy Briefing 9

What would change in the tax environment?While the extent of change cannot be predicted with any certainty at this stage, there is a range of areas where Brexit could result in significant changes in tax and tax policy.

• Customs and excise: As a current member of the EU, the UK applies the Common Customs Tariff to goods entering the UK from outside the Union. This is managed by the EU itself and so, if the UK wished to continue charging tariffs on imports, it would need to legislate for a domestic tariff system. Excise duties are not fully harmonized in the EU, and the UK would be able to maintain its present system.

Furthermore, if a new model was not agreed upon, the UK would be seen to follow the World Trade Organization rules, which would expose UK exports into the EU to the Common Customs Tariff, increasing both financial costs and probably time taken to import into the EU.

• VAT: It is likely that the UK will largely retain the current system of value-added tax (VAT) on leaving the EU, particularly since VAT is directly enacted into UK law. However, taxpayers would no longer have a right of appeal to the Court of Justice of the European Union, and the UK Government would have additional flexibility on setting the rates and scope of VAT. Furthermore, UK businesses would find themselves exposed to VAT on purchases in the EU, with potentially a significant delay in getting refunds.

• Withholding tax: UK groups would no longer be able to benefit from the withholding tax exemptions in the EU Parent-Subsidiary Directive and the Interest and Royalties Directive once the UK leaves. Not all existing UK tax treaties provide for a zero withholding tax; as a result, the updating of the tax treaty network is expected to be a high priority for these companies, which may wish to review where they rely on EU directives to mitigate withholding tax.

• Treaties: Many treaties between the US and EU Member States require EU membership for equivalent beneficiary treatment under the limitation of benefits clause of the treaty, a test which, once there has been a formal exit, the UK would no longer meet. This may affect those groups that have a UK tax resident-listed ultimate parent and flows of interest, dividends or royalties from their US subgroup to a financing, holding or intellectual property-owning company in Europe. These groups will need to review their current and any planned future structures to assess their ability to access treaty benefits post-Brexit.

• Labor mobility: At present, the rules governing where mobile workers pay their social contributions and how their entitlement to social security benefits are aggregated are coordinated at the EU level. If the EU migrant worker regulation did not apply to the UK, employers sending workers cross-border would need to navigate a complex network of bilateral agreements. This may raise risks of greater complexity and increase administrative burdens when posting workers between the EU and UK.

• State Aid: The EU’s State Aid rules may no longer apply to the UK after it leaves. This may affect the development of ongoing investigations, and direct tax measures that in the past were found to constitute State Aid may be revived in the medium term.

• EU tax initiatives: Subject to the terms under which the UK leaves the EU, it is unlikely that the UK will be party to various tax initiatives currently in progress in Brussels, such as the EU Anti-Tax Avoidance Directive, public country-by-country reporting and the common consolidated corporate tax base. However, where the UK has supported these initiatives, we would expect the UK to continue to push ahead with similar legislation. The UK will also continue to participate actively in the OECD’s BEPS agenda.

What should be your key priorities?The impact of Brexit on companies will depend on the extent of their business relationships with the UK. Of course, those companies with a physical location in Britain will feel those changes more heavily. But even those companies with a tangential relationship with the UK may be affected. Key areas that deserve special attention to assess the impact of Brexit are the following:

Global Tax Policy and Controversy Briefing10

,

Considerations Potential impact

Speed of action

Forex/treasury ► What are the tax consequences of managing your treasury position?

Trading model/operating model

► What are the trade, duties and VAT implications for your supply chain?► How will your people functions be affected?► How will you need to adjust your transfer pricing?

Systems ► How will you manage an increased compliance burden, e.g., duties and VAT?► How will it affect entity reporting?

People ► What data do you hold on European nationals working for you in the UK and British citizens working in Europe?

► As the profile of the workforce is set to change, how integrated are your immigration, employment and talent strategies?

Legal structure ► Is your headquarter location fit for purpose?► Could the removal of EU directives impact the tax and legal profile of your existing

group structure?

Regulatory change

► Are you aware to what extent your business relies on EU regulations that might no longer apply in the future?

Future of UK tax ► What do you need the UK tax regime to deliver to help you remain competitive?

H M L

H M L

H M L

H M L

H M L

H M L

H M L

H M L

H M L

H M L

H M L

H M L

H M L

H M L

What to do now?None of the questions above have a straightforward answer. The next couple of years will be crucial to assessing the impact of Brexit on companies and their employees. We are seeing companies plan for the future, but they need to avoid preempting the decisions that will follow from both the UK and the EU.

The key actions now are the following:

• Evaluate the potential risk areas• Consider the timeline for those risks• Develop an outline plan for

responding to the risks• Identify the triggers for action• Monitor developments

All of this spans far more than tax alone, and leading companies are ensuring that the tax team is embedded in their Brexit steering committees. The vote on 23 June was only the starting point, and where the finish line leads is not yet known. In such an uncertain situation, new information is clearly needed. Look out for the Autumn Statement.

The dashboard below summarizes some of the key questions that will be important to address in assessing the impact of Brexit on individual businesses.

Scenario drivers for consideration

Potential tax and legal implications

TradeExports to EU, access to markets, imports (supply chain) from EU, impact on customers

PeopleImpact on ability to hire skilled and unskilled staff, possible wage pressure, impact on existing staff

RegulationChanges to regulation of products and services, impact on business model, standards and future investment

Government policyAccess to EU research funding, taxation, greater flexibility in design and implementation of investment incentives including the UK competitive tax policy

Global Tax Policy and Controversy Briefing 11

EY contacts

Chris Sanger Rob Hanson

EY Global Tax Policy Leader EY Global Tax Controversy Leader csanger@uk.ey.com rob.hanson@ey.com +44 20 7951 0150 +1 202 327 5696

Global Leaders

EY AmericasJurisdiction Tax policy Tax controversy

Tax policy and controversy leaders

Cathy Kochcathy.koch@ey.com+1 202 327 7483

Rob Hansonrob.hanson@ey.com +1 202 327 5696

Argentina Carlos Casanovascarlos.casanovas@ar.ey.com+54 11 4318 1619

Felipe-Carlos Stepanenkofelipe-carlos.stepanenko@ar.ey.com +54 11 4318 1777

Brazil Washington Coelhowashington.coelho@br.ey.com +55 11 2573 3446

Frederico Godfrederico.h.god@br.ey.com +55 11 2573 3232

Canada Gary Zedgary.zed@ca.ey.com +1 403 206 5052

Gary Zedgary.zed@ca.ey.com +1 403 206 5052

Chile Osiel Gonzálezosiel.gonzalez@cl.ey.com+56 2 676 1141

Carlos Martínezcarlos.martinez.c@cl.ey.com+56 2 676 1710

Colombia Margarita Salasmargarita.salas@co.ey.com +57 1 484 7110

Margarita Salasmargarita.salas@co.ey.com +57 1 484 7110

Costa Rica Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Dominican Republic Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Ecuador Fernanda Checafernanda.checa@ec.ey.com+593 2 255 3109

Fernanda Checafernanda.checa@ec.ey.com+593 2 255 3109

El Salvador Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Global Tax Policy and Controversy Briefing66

EY AmericasJurisdiction Tax policy Tax controversy

Guatemala Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Honduras Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Israel Arie Pundakarie.pundak@il.ey.com+972 3 568 7115

Gilad Shovalgilad.shoval@il.ey.com+972 3 623 2796

Mexico Jorge Librerosjorge.libreros@mx.ey.com+52 55 5283 1439

Enrique Ramirezenrique.ramirez@mx.ey.com+52 55 5283 1367

Nicaragua Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Rafael Sayaguésrafael.sayagues@cr.ey.com+506 2208 9880

Panama Luis Ocandoluis.ocando@pa.ey.com+507 208 0144

Luis Ocandoluis.ocando@pa.ey.com+507 208 0144

Peru David de la Torredavid.de.la.torre@pe.ey.com+51 1 411 4471

David de la Torredavid.de.la.torre@pe.ey.com+51 1 411 4471

Puerto Rico Teresita Fuentesteresita.fuentes@ey.com+1 787 772 7066

Teresita Fuentesteresita.fuentes@ey.com+1 787 772 7066

United States Nick Giordanonick.giordano@wc.ey.com+1 202 467 4316

Heather Maloyheather.maloy@ey.com +1 202 327 7758

Venezuela Jose Velazquezjose.a.velazquez@ve.ey.com+58 212 905 6659

Jose Velazquezjose.a.velazquez@ve.ey.com+58 212 905 6659

Global Tax Policy and Controversy Briefing 67

EY Asia-PacificJurisdiction Tax policy Tax controversy

Tax policy and controversy leaders

Alf Capitoalf.capito@au.ey.com+61 2 8295 6473

Howard Adamshoward.adams@au.ey.com+61 2 9248 5601

Australia Alf Capitoalf.capito@au.ey.com+61 2 8295 6473

Martin Caplicemartin.caplice@au.ey.com+61 8 9429 2246

China Becky Laibecky.lai@hk.ey.com+852 2629 3188

Lawrence Cheunglawrence-f.cheung@cn.ey.com+86 755 2502 8383

Hong Kong SAR Becky Laibecky.lai@hk.ey.com+852 2629 3188

Wilson Chengwilson.cheng@hk.ey.com+852 2846 9066

Indonesia Yudie Paimantayudie.paimanta@id.ey.com+62 21 5289 5585

Yudie Paimantayudie.paimanta@id.ey.com+62 21 5289 5585

Malaysia Amarjeet Singhamarjeet.singh@my.ey.com+60 3 7495 8383

Amarjeet Singhamarjeet.singh@my.ey.com+60 3 7495 8383

New Zealand Aaron Quintalaaron.quintal@nz.ey.com+64 9 300 7059

Kirsty Keatingkirsty.keating@nz.ey.com+64 9 300 7073

Philippines Wilfredo U. Villanuevawilfredo.u.villanueva@ph.ey.com+63 2 894 8180

Luis Jose P. Ferrerluis.jose.p.ferrer@ph.ey.com+632 894-8362

Singapore Russell Aubreyrussell.aubrey@sg.ey.com+65 6309 8690

Siew Moon Simsiew-moon.sim@sg.ey.com+65 6309 8807

South Korea Dong Chul Kimdong-chul.kim@kr.ey.com+82 2 3770 0903

Dong Chul Kimdong-chul.kim@kr.ey.com+82 2 3770 0903

Taiwan ChienHua Yangchienhua.yang@tw.ey.com+886 2 2757 8888

ChienHua Yangchienhua.yang@tw.ey.com+886 2 2757 8888

Thailand Yupa Wichitkraisornyupa.wichitkraisorn@th.ey.com+66 2 264 0777

Yupa Wichitkraisornyupa.wichitkraisorn@th.ey.com+66 2 264 0777

Vietnam Huong Vuhuong.vu@vn.ey.com+84 9 0343 2791

Huong Vuhuong.vu@vn.ey.com+84 9 0343 2791

Global Tax Policy and Controversy Briefing68

EY EMEIAJurisdiction Tax policy Tax controversy

Tax policy and controversy leaders

Jean-Pierre Liebjean.pierre.lieb@ey-avocats.com+33 1 55 61 16 10

Jean-Pierre Liebjean.pierre.lieb@ey-avocats.com+33 1 55 61 16 10

Austria Andreas Stefanerandreas.stefaner@at.ey.com+43 1 21170 1040

Andreas Stefanerandreas.stefaner@at.ey.com+43 1 21170 1040

Belgium Herwig Joostenherwig.joosten@be.ey.com+32 2 774 9349

Leen Ketelsleen.ketels@be.ey.com+32 2 774 6022

Bulgaria Milen Raikovmilen.raikov@bg.ey.com+359 2 8177 100

Milen Raikovmilen.raikov@bg.ey.com+359 2 8177 100

Croatia Denes Szabodenes.szabo@hr.ey.com+386 31 67 47 80

Masa Saricmasa.saric@hr.ey.com@hr.ey.com+385 1 580 0935

Cyprus Philippos Raptopoulosphilippos.raptopoulos@cy.ey.com +357 25 209 999

Philippos Raptopoulosphilippos.raptopoulos@cy.ey.com +357 25 209 999

Czech Republic Lucie Rihovalucie.rihova@cz.ey.com+420 225 335 504

Lucie Rihovalucie.rihova@cz.ey.com+420 225 335 504

Denmark Jens Wittendorfjens.wittendorff@dk.ey.com+45 51 58 2820

Bjarne Gimsingbjarne.gimsing@dk.ey.com+45 25 29 3699

Johannes Larsenjohannes.r.larsen@dk.ey.com+45 73 23 3414

Estonia Ranno Tingasranno.tingas@ee.ey.com+372 611 4578

Ranno Tingasranno.tingas@ee.ey.com+372 611 4578

European Union Marnix Van Rijmarnix.van.rij@nl.ey.com+31 70 328 6742

Klaus Von Brockeklaus.von.brocke@de.ey.com+49 89 14331 12287

Finland Jukka Lyijynenjukka.lyijynen@fi.ey.com+358 207 280 190

Jukka Lyijynenjukka.lyijynen@fi.ey.com+358 207 280 190

France Charles Menardcharles.menard@ey-avocats.com+33 1 55 61 15 57

Charles Menardcharles.menard@ey-avocats.com+33 1 55 61 15 57

Germany Hermann Ottmar Gaußhermann.gauss@de.ey.com+49 30 25471 16242

Jürgen Schimmelejuergen.schimmele@de.ey.com+49 211 9352 21937

Global Tax Policy and Controversy Briefing 69

EY EMEIAJurisdiction Tax policy Tax controversy

Greece Stefanos Mitsiosstefanos.mitsios@gr.ey.com+302 102 886 365

Tassos Anastassiadistassos.anastassiadis@gr.ey.com+302 102 886 592

Hungary Botond Renczbotond.rencz@hu.ey.com+36 145 18602

Botond Renczbotond.rencz@hu.ey.com+36 145 18602

India Ganesh Rajganesh.raj@in.ey.com+91 120 6717110

Rajan Vorarajan.vora@in.ey.com+91 22 619 20440

Ireland Kevin McLoughlinkevin.mcloughlin@ie.ey.com+353 1 2212 478

Kevin McLoughlinkevin.mcloughlin@ie.ey.com+353 1 2212 478

Italy Giacomo Albanoglacomo.albano@it.ey.com+39 0685567338

Maria Antonietta Biscozzimaria-antonietta.biscozzi@it.ey.com+39 02 8514312

Kazakhstan Konstantin Yurchenko konstantin.yurchenko@kz.ey.com+7 495 641 2958

Konstantin Yurchenko konstantin.yurchenko@kz.ey.com+7 495 641 2958

Latvia Ilona Butaneilona.butane@lv.ey.com+371 6704 3836

Ilona Butaneilona.butane@lv.ey.com+371 6704 3836

Lithuania Kestutis Lisauskaskestutis.lisauskas@lt.ey.com+370 5 274 2252

Kestutis Lisauskaskestutis.lisauskas@lt.ey.com+370 5 274 2252

Luxembourg Marc Schmitzmarc.schmitz@lu.ey.com+352 42 124 7352

John Hamesjohn.hames@lu.ey.com+352 42 124 7256

Malta Robert Attardrobert.attard@mt.ey.com+356 2134 2134

Robert Attardrobert.attard@mt.ey.com+356 2134 2134

Middle East Balaji Ganesh balaji.ganesh@kw.ey.com+202 27260260

Balaji Ganesh balaji.ganesh@kw.ey.com+202 27260260

The Netherlands Arjo van Eijsdenarjo.van.eijsden@nl.ey.com+31 10 406 8506

Arjo van Eijsdenarjo.van.eijsden@nl.ey.com+31 10 406 8506

Norway Arild Vestengenarild.vestengen@n0.ey.com+47 24 002 592

Arild Vestengenarild.vestengen@n0.ey.com+47 24 002 592

Poland Zbigniew Liptakzbigniew.liptak@pl.ey.com+48 22 557 7025

Agnieszka Talasiewiczagnieszka.talasiewicz@pl.ey.com+48 22 557 72 80

Portugal Carlos Manuel Baptista Lobocarlos.lobo@pt.ey.com+351 217 912 000

Paulo Mendoncapaulo.mendonca@pt.ey.com+351 21 791 2045

Global Tax Policy and Controversy Briefing70

EY EMEIAJurisdiction Tax policy Tax controversy

Romania Emanuel Bancila emanuel.bancila@ro.ey.com+40 21 402 4100

Emanuel Bancila emanuel.bancila@ro.ey.com+40 21 402 4100

Russia Alexandra Lobovaalexandra.lobova@ru.ey.com+7 495 705 9730

Alexei A. Nesterenko alexei.nesterenko@ru.ey.com+7 495 662 9319

Slovak Republic Richard Panekrichard.panek@sk.ey.com+421 2 333 39109

Peter Feilerpeter.feiler@sk.ey.com+421 2 333 3915

Slovenia Denes Szabodenes.szabo@hr.ey.com+386 31 67 47 80

Denes Szabodenes.szabo@hr.ey.com+386 31 67 47 80

South Africa Lucia Hlongwanelucia.hlongwane@za.ey.com+27 76 830 4144

Christel Van Wykchristel.vanwyk@za.ey.com+27 11 502 0100

Spain Eduardo Verdun Fraileeduardo.verdunfraile@es.ey.com+34 915 727 419

Maximino Linaresmaximino.linaresgil@es.ey.com+34 91 572 71 23

Sweden Erik Hultmanerik.hultman@se.ey.com+46 8 5205 9468

Erik Hultmanerik.hultman@se.ey.com+46 8 5205 9468

Switzerland Roger Krapfroger.krapf@ch.ey.com+41 58 286 2125

Martin Hubermartin.huber@ch.ey.com +41 58 286 6120

Turkey Erdal Calikogluerdal.calikoglu@tr.ey.com+90 212 408 53 75

Erdal Calikogluerdal.calikoglu@tr.ey.com+90 212 408 53 75

Ukraine Vladimir Kotenkovladimir.kotemko@ua.ey.com+380 44 490 3006

Vladimir Kotenkovladimir.kotemko@ua.ey.com+380 44 490 3006

United Kingdom Chris Sangercsanger@uk.ey.com+44 20 7951 0150

James Wilsonjwilson8@uk.ey.com+44 20 7951 5912

EY JapanJurisdiction Tax policy Tax controversy

Tax policy and controversy leaders

Alf Capitoalf.capito@au.ey.com+61 2 8295 6473

Howard Adamshoward.adams@au.ey.com+61 2 9248 5601

Japan Koichi Sekiya koichi.sekiya@jp.ey.com+81 3 3506 2447

Koichi Sekiya koichi.sekiya@jp.ey.com+81 3 3506 2447

Global Tax Policy and Controversy Briefing 71

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